IR 05000155/1998008

Insp Rept 50-155/98-08 on 980827-1130.No Violations Noted. Major Areas Inspected:Radiological Safety

ML20196H331
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/03/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196H321	List: IR 05000155/1998008 ML20196H317
References
50-155-98-08, 50-155-98-8, NUDOCS 9812090046
Download: ML20196H331 (6)

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U.S. NUCLEAR REGULATORY COMMISSION i

REGIONlli Docket No:

50-155 License No:

DPR-06

Report No:

50-155/98008(DNMS)

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i Licensee:

Consumers Energy Company i

Facility:

Big Rock Point Restoration Project Location:

10269 US 31 North I

Charlevoix, MI 49720

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Dates:

August 27 - November 30,1998

i inspectors:

D. W. Nelson, M.S., Radiation Specialist i

Approved By:

Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety 9812090046 981203 PDR ADOCK 05000155 G

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EXECUTIVE SUMMARY Big Rock Point Restoration Project NRC Inspection Report 50-155/98008(DNMS)

Radioloaical Safety G:,od progress was being made in implementing needed improvements in the Radiation e

Protection & Environmental Services Program.

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As-Low-As-Reasonably-Achievable planning for the Reactor Coolant Pump Room and

Steam Drum Room hot spot removal project was well researched and comprehensive.

Measures to strengthen control of radwaste segregation, packaging and shipping were e

in effect which resulted in significant improvement in the radwaste program.

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j Report Details j

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Summary of Plant Activities

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Corrective actions to address weaknesses in the Radiation Protection & Environmental f

i Services (RP&ES) Program continued during the inspection period. The

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As-Low-as-Reasonably-Achievable (ALARA) planning for the Reactor Coolant Pump

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(RCP) and Steam Drum (SD) rooms hot spot removal project was completed.

l 1.0 Radiological Safety

1.2 Qnnggj i

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' The inspector conducted reviews of ongoing activities in order to assess the overall

Radiation Protection (RP) Program. Specific findings are detailed in the sections j

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1.2 Occupational Radiation Exoosure I

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Insoection Scooe (83750). -

l The inspection examined and evaluated aspects of the RP&ES Program. Specific L

areas evaluated include staffing, ALARA planning and the actions taken to correct l

. deficiencies that had been identified in the RP&ES Program.

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Observations and Findinos

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On September 14,1998, new superintendents were appointed in the RP Radwaste l

and RP Operations groups. In addition to the new appointrrents, the licensee made

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changes in the RP organizational structure and assigned a number of individuals to

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new positions. The effect of the changes in the organization will be tracked during future inspections.

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l In inspection Report 50-155/98005(DNMS), weaknesses that had been identified by

the licensee and the NRC in the RP&ES Program were discussed. Following that inspection, the licensee generated a Level 1 Condition Report to address and correct those weaknesses. RP and plant management developed a formal plan, the *RP&ES Master Plan" dated October 20,1998, to address each of the RP programmatic t

weaknesses identified in the Condition Report. The plan clearly defined the areas in the RP&ES Program that needed improvement and set milestone dates for each step

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in the improvement process. The plan also assigned resources, named interfaces

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with other departments (programs) and defined the risks from not correcting the

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programmatic weaknesses.

l During an interview with the Manager of RP&ES, the Manager indicated that while I

significent progress had been made toward implementing the Master Plan, there were areas that not been addressed. For example, while many of the corrective actions outlined in the Master Plan for the Radwaste Shipping and Handling Program had

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l been implemented, several in the plan to correct radworker deficiencies had not yet begun. Back-to-Basic training for radworkers, for instance, had been delayed awaiting

completion of training on the new Technical Specifications. While it was too early to

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judge the effectiveness of the proposed corrective actions on the RP&ES Program as a whole, the plan appeared to serve as a good model for addressing RP programmatic weaknesses.

During the month of October the licensee removed hot spots from the RCP and SD rooms. The inspector interviewed the ALARA Planner responsible for the project.

The Planner was not only responsible for the project ALARA planning but developed the project's dose budget as well as assisting with generating the prcject Radiation Work Permits (RWP), ALARA reviews and the Pre-Job Checklists. The inspector also reviewed the ALARA Review (108), the RWP (98030) and the Pre-Job Checklist (108)

generated for the removal of one of the hot spots. The ALARA Planner appeared have donc considerable research on the system configurations in the RCP and SD

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rooms and was knowledgeable about the current and historical radiological conditions at the work site and the radiological risks associated with the project. The interview and a review of the project documents indicated that the project had been well researched and planned. The protective measures adopted for the project appeared

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to accurately reflect the radiological risks at the work site and the project documents appeared to be comprehensive in scope, informative and for the most part user friendly.

During a meeting with RP&ES personnel, concems were expressed regarding the licensee's delay in performing Back-to-Basic training for radiation workers. The NRC was concemed that the lack of retraining would continue to negatively impact worker performance. For example, inappropriate material continued to be found in waste receptacles resulting in the need for onsite segregation of trash. The RP&ES manager acknowledged this concern and indicated that the training would be

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forthcoming.

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Conclusions The licensee appeared to be making good progress in addressing some of the l

weaknesses in the RP&ES Program identified in previous inspection reports. The planning for the RCP Room a'd SD Room hot spot removal project appeared to be well researched and comprehensive in scope. The project's associated documents appeared to be user friendly and the content accurately reflected the radiological conditions at the work site.

1.3 Solid Radioactive Waste Manaaement and Transoortation of Radioactive Materials

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a.

Insoection Scope (86750)

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The ins sector interviewed the Radwaste Superintendent and toured Room 121 located in the Auxiliary Building and tlie RadWaste Building.

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Observations and Findinas Since the end of the last inspection period, several significant changes have been made in the Radioactive Waste Management and Radioactive Materials Shipping Program. The changes were made in response to transportation incidents in which inappropriate material was found in containers shipped to a radioactive waste vendor for processing and in containers awaiting shipment. Those incidents were reported in

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Condition Reports C-BRP-98-0038 (mercury), C-BRP-98-0038 (oil in a motor and gear

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box) and C-BRP-98-223 (trash labeled with a lead dust hazard notice and

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one vacuum cleaner labeled as containing asbestos). To correct those deficiencies and close the aforementioned Condition Reports, changes were made in the program l

and those changes were reviewed during the inspection.

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On September 9,1998, a new Radwaste Superintendent was appointed and one of

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his responsibilities was to correct the deficiencies identified in the Condition Reports.

During the interview the Superintendent indicated that many of the corrective actions that had been taken involved the manner in which potentially contaminated waste was segregated, stored, packaged and inspected prior to shipment. For example, l

hazardous and mixed waste would no longer be stored in the Radwaste Building. All such waste would be examined and moved into an adjacent temporary structure. Only non-hazardous contaminated waste " ready for shipment" would be stored in the Radwaste Building.

In addition, to prevent inappropriate materials from being shipped offsite, all containers housing radioactive waste were opened and examined. In addition, a sorting room j

was constructed in Room 121 of the Auxiliary Building and the room was used to examine, sort and segregate all waste before the waste was packaged for shipment.

l The inspector noted that the opening of containers and the segregation of waste had begun in October 1998 and had continued throughout the inspection period.

Other changes in the program included the purchase of colored bags to differentiate l.

between clean, contaminated and hazardous waste, the building of a fence around the l

west side of the Radwaste Building, an enhanced and energized Quality Control l

Program and the packaging of radioactive waste at the source of the contamination.

l While not all of these changes have been fully implemented, the Superintendent

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l indicated that other changes may be adopted as the facility continues to reevaluate the program through the facility's self-assessment program.

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Conclusions Significant improvements were noted in the radwaste program.

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Exit Meeting Summary The inspector presented the inspection results to members of the radiation protection staff during the onsite portion of the inspection, and by telephone to the Plant General Manager on December 3,1998. The licensee acknowledged the findings presented. The licensee did not identify any of the documents or processes reviewed by the inspector as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED l

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M. Bourassa, Licensing Supervisor j

l O. Hale, Radiation Protection Operations Superintendent.

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K Pallagi, Radiation Protection and Environmental Manager

' G. Rowell, Corrective Action Supervisor

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G. Szczotka, Manager Nuclear Performance Assessment Department R. Wills, Radweste Superintendent l

G. Wdhrow, Engineering Manager

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INSPECTION, PROCEDURES USED IP 83750:

, Occupational Radiation Exposure IP 86750:

Solid Radweste Management and Transportation of Radioactive Materials LICENSEE DOCUMENTS REVIEWED I

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Radiation Protection & Environmental Services Master Plan Index Radiation Work Permit 982030 Pre-Job Checklist 108 Al. ARA Review 108 l

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